On January 9th the Strategic Growth Council published the Final Draft Guidelines and staff report for the Affordable Housing and Sustainable Communities program in anticipation of a formal vote to approve them on Tuesday, January 20, 2015. Although the new draft addresses a number of important concerns, it makes a huge change in point scoring and methodology that we believe will significantly disadvantage affordable housing proposals that would actually reduce Greenhouse Gases (GHG) far more. 

Summary of Changes to AHSC Guidelines

1. Increased reliance on outdated GHG formula will hurt deeper affordability and preservation. By far the largest number of points (55 out of 100) will now be based on estimated GHG reductions using the outdated CalEEMod score divided by total AHSC funds requested. While measuring GHG reductions is an important goal of the program, the CalEEMod methodology essentially disregards all recent evidence that lower-income households drive substantially less than other households, including the analysis prepared by the Center for Neighborhood Technology for the California Housing Partnership and TransForm using comprehensive new data from CalTrans. Relying this heavily on CalEEMod will also disadvantage proposals that focus on preserving existing low-income housing and preventing displacement of existing low-income households from new AHSC investments, which was an important goal of the authorizing legislation.
    
2. Affordability points set at a maximum of 6.5 out of 100 points. Since the definition of "Affordable Unit" includes serving households earning up to 80% of the Area Median Income, this means that there is very little incentive to serve the Extremely Low- and Very-Low Income households that the CHPC/TransForm/CNT Ford Foundation/Housing California-funded report found have approximately 25% lower Vehicle Miles Travelled (VMT).
    
3. Minimum project size requirement are now eliminated, but larger projects will likely still be favored by the use of the CalEEMod score.
    
4. Minimum net density requirements have been lowered to reflect State default densities, but too wide a range of counties are now considered "urban" meaning that many GHG-reducing affordable housing developments in more rural and suburban areas in counties such as Placer and Yolo will now be excluded from applying for these funds.
    
5. The public agency co-applicant requirement is now eliminated, but the joint and several liability requirement remains.
    
6. ICP applications still do not have to have any affordable housing in them. All applications should have to have a significant affordable housing component. 

Take Action Now!

There is very limited opportunity for comment given the program's aggressive timeline. Please email members of the Strategic Growth Council by COB tomorrow (Friday, Jan 16) with the following requests for changes and/or attend the SGC meeting to give public comments:  

1. Reduce the points given to CalEEMod scores and give these points back to affordability. In recognition of the well-documented fact that CalEEMod significantly underestimates the lower VMTs of lower income households, shift at least 20 of the currently recommended 55 points from the CalEEMod score to the affordability score.  This change would result in a more balanced relationship of 35 points for CalEEMod and 26.5 points for affordability. It would also make it less likely that larger projects will dominate the awards.   
    
2. Redefine density requirements so that jurisdictions with state defined rural areas are held to the "rural" density standards even within "urban" and "suburban" counties.  Also, jurisdictions within "urban" counties with fewer than 100,000 people should be held to "suburban" density standards.
    
3. Eliminate the joint and several liability requirement or find a way to substantially limit the scope of the liability so that concern about it does not prevent applications from being submitted.
    
4. Require that all Integrated Connectivity Project applications include an affordable housing component. If we improve transit in the ICP areas but do not add or preserve affordable homes, it is likely we will see lower transit ridership and therefore lower than expected GHG reductions. Further, as land values increase, it will be more difficult to develop affordable homes later on, leading to greater displacement of lower-income households as a result of AHSC investments, which would be contrary to legislative intent.  

AHSC Timeline

Jan. 20: Strategic Growth Council votes on guidelines

Jan. 26 - Jan. 30: NOFA released

Early February: NOFA workshops and Technical Assistance

Feb. 19: Concept Proposal Due to HCD

Mar. 11: Invitation to Submit Full Application

April 15: Full applications Due

Mid-June 2015: Staff Award Recommendation Released

Late June 2015: Council Considers and approves staff recommendations for awards

 The California Housing Partnership will work with Housing California and other Sustainable Communities for All leaders to make the above requests to all SGC members leading up to the vote on Tuesday. Please contact Megan Kirkeby mkirkeby@chpc.net with any questions and copy her on any correspondence.